United States Tax Court February 8, 1993, Docket No. 106-91 (Hong v. Commissioner)

lead-opinion

OPINION

Ruwe, Judge:

This case was assigned to Special Trial Judge Helen A. Buckley pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.1 After a review of the record, we agree with and adopt her opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

Buckley, Special Trial Judge:

This case is before us on petitioners’ motion for attorney’s fees.